The open data community often talks about how open government programmes let volunteer developers and civil society funded projects help end users such as citizens, taxpayers and voters but the largest end users of open data are typically governments, financial services companies, international charities and even gambling companies.
I originally configured a map in late 2011 to help less digital end users at the Isle of Man Government in Income Tax, economic development, foreign aid and regulators leverage other government open data as an opportunity to demonstrate value and to build momentum on an open government programme. It helped visualise incorporations to non-technical end users and helped end users without English to access the data:
Corporate Register: Isle of Man
With previous expertise as a legal compliance officer in an offshore companies registry and as a group IT manager in global wealth managers and, prompted by email threads with Chris Taggart, James McKinney and others, I realised that Incorporations League Tables could visualise expertise by SIC code and year on year market share trends but it also surfaced issues such as free text registered office addresses, free text officer names, aged shelf companies, excessive directorships and client dumping in SAR frameworks:
Incorporations League Table: Isle of Man
I recently noted 31 extra jurisdictions since early 2015 and updated the map:
Canada: New Brunswick
Canada: Newfoundland and Labrador
USA: New Hampshire
USA: New York
USA: North Carolina
USA: North Dakota
USA: South Carolina
Is there a prioritised list of extra jurisdictions and is it reshaped by events such as #PanamaPapers or just limited by volunteer efforts?
A response to an #opendata movement exchange between Tom Steinberg (founder MySociety UK) and John Wonderlich (director Sunlight Foundation USA) about the importance of outrage from someone that struggles to push and to collaborate on open government at the same time in parliament, in government and in large corporates:
It has taken 10+ years effort to earn the trust to successfully identify and cajole the *right* career civil servants and the *right* politicians to go to an open data bootcamp.
The efforts are certainly built on outrage.
I believe I am the only person in the Isle of Man to go to court over the code of practice on access to information with the Companies Registry and one of the reasons I ended up helping Chris Taggart at opencorporates to webscrape Liechtenstein, Gibraltar, Cyprus, etc. In a small and, more importantly, offshore jurisdiction that is usually very career defining (a.k.a. limited to the private sector). That is outrage.
I have allocated 80% annual leave for years and “volunteer” for anything that earns time in lieu (no paid overtime anyway) to attend TransparencyCamp in Washington DC for the masterclasses or RISE in Hong Kong to help push harder on #blockchain. I have explored how to help get cash directly into the hands of beneficiaries with the bitcoin XBT currency code in the global aid flow database and then just did it because no-one else would in my timescale. That is outrage.
I have been on that cold train station platform late on a Sunday at the end of an exciting but draining unconference when a career civil servant says they are looking forward to the next 2 days time in lieu to recover and you have to go to the day job. That is outrage.
Yes, the funding mechanisms are broken and the Open Contracting Data Standard will probably not help fast enough to help the early stage open data generation. I have made some difficult decisions already in 2016. I have had 2 direct debits bounce and my credit reference is impacted. That is outrage.
I was at the Open Knowledge bootcamps in London, Warsaw, Helsinki, Geneva and Berlin but increasingly only the handfuls that ended up with some government funding were still able to afford or to justify self-funding from other consultancy. Tech startups know or eventually learn that fundraising is increasingly a full-time role and only successful if you have a CTO co-founder to help the fundraising. The rightest and brightest ideas needlessly slip through the fingers of society every month and I am powerless to stop it. That is outrage.
Just last night, I hosted a parliament session with a small group of 16+ year olds in care to debate a motion for the government to substantially fund driving lessons as they do not have parents to subsidise or to practice driving at weekends. A quiet girl had exhaustively researched driving lesson costs (average GBP 28 per hour) and average lessons (47) and costs. A young mother with a baby had powerful points and the director of childrens services agreed in principle to amend the department policy. I was humbled. I recognise channelled outrage.
I have made the right decision. Collaboration and hacktivist. Open data, when do we want it, now! ;O)
I’ve blogged before about the pipeline of pending bitcoin milestones and country growth hacking so I should highlight progress on XBT as a currency code.
I attended the open data summit in Ottawa in May 2015 and prompted by some hardcore Q&A I decided to unblock the stalemate on BTC as a currency code.
I discovered that the United Nations and World Bank supported global aid flow database already includes a mechanism to include politically sensitive currency codes. X is used as a prefix to the established currency code BTC and truncated to 3 characters, i.e. XBT.
A draft strategy emerged in the corridors at a fringe unconference on Saturday and fermented at a micro brewery in Gatineau (Quebec) on Saturday night:
register a wallet with a bitcoin operator based in the same country as the charity
process a cross-border bitcoin transaction
handcode the bitcoin transaction as cross-border aid flow in an XML aid flow transaction file to include XBT as the currency code
leverage an Isle of Man login to the global aid flow database to upload the cross border aid flow transaction file — ok, the system was developed to process millions of dollars/pounds/swiss francs/etc but millibits sounds like millions
request that the IATI technical support team add an XBT currency code to the official code list to stop validation errors in thousands of aid flow management systems and apps linked to the IATI API
With due diligence on shortlisted charities and previous bitcoin transactions via Blockchain Luxembourg, firstly I selected a German charity Amani Kinderdorf with projects in Africa to support AIDS orphans and secondly I selected a German bitcoin wallet operator cubits based on personal recommendations.
Disclosure: I subsequently accepted an advisory board member role for 3 months to research bitcoin mass adoption.
On 11th September 2015 IATI started a private consultation on XBT as a currency code within the IATI Technical Advisory Group.
Disclosure: I am a member of the IATI TAG.
On 1st October 2015 it was confirmed that XBT had been added as a currency code to the IATI global aid flow database system emdorsed and supported by the United Nations, the World Bank, etc.
I have accumulated extensive relevant expertise via 2 years on the Bank of England currency tracking system, the Open Bank Project (the first batch at Level39), a 1 year open banking placement at the Treasury in the Isle of Man Government and bitcoin milestones, so I have had some interesting discussions on possibilities with potential partners in Dublin, Zurich, Luxembourg, New York, Melbourne, etc.
Obviously I have followed the Barclays project with Safello and they are expected to support bitcoin charity donations in Q4 2015 or Q1 2016.
Disclosure: I applied to the Barclays Techstars fintech accelerator.
I had previously discussed a large opportunity in wealth management with Cayman National Bank and, prompted by the announcement of the HM Treasury Open Banking Working Group chaired by Barclays and the Open Data Institute, more recently with Barclays Isle of Man. Cayman National Bank didn’t have the right existing client profile but I think Barclays will need to do the London thing before it has enough internal momentum to progress something more ambitious offshore.
I defined and requested that Jersey, Guernsey and Gibraltar corporate register and charity regulator reference codes should be added to the global aid flow database system. Jersey and Guernsey have been added but Gibraltar does not presently meet all the technical requirements.
On 10th November 2015, I flagged a hidden issue at an excellent Wragge Lawrence Graham fintech event with a great keynote by Bob Ferguson from the FCA and “ask me anything” fintech VC panel — actually lots of fintech milestones are self-funded so a mechanism to fund or to refund hacktivist research could accelerate progress in any jurisdiction.
The regulatory sandbox at the UK FCA with a government umbrella company and representative appointment risk management mechanism is real world help to support fintech startups and to let large operators dip their toes in the water and even fail small.
A little reported response to the Paris attacks was to increase aid flow to fragile states from 30% to at least 50% — the jurisdictions at highest risk of diversion. So the need to maximise financial reporting at lowest cost, the need to visualise soft power dynamics and ultimately the need to demonstrate sustainable social impact will support a shift to blockchain technology, daily micropayments direct beneficiaries and perhaps even a BIP to automatically allocate some bitcoin ecosystem processing to the nearest direct beneficiary mobile phone as an income stream.
At the RISE conference in Hong Kong I arranged to follow up on key points with Bobby Lee. Downstairs at the Facebook developers bootcamp I noted that Facebook had hired talent from Ripple etc and that, for example, mainstream bitcoin apps would be ok.
On 18th November 2015, Facebook launched the non-profit donations option but I would expect the most progressive social impact via the internet.org initiative.
Next week, I will progress a bitcoin milestone in London that should indirectly progress Banknotey, a platform to finally extend ebusiness to cash customers so they can have a better life too.
Prompted by the news coverage of Nepal, the IATI TAG unconference in Ottawa next week and an open data superhero like Bibhusan Bista, I thought I would look at the world class UK Government open data and the level of IATI engagement.
I assumed that IATI would become the natural hub to share real time open data and to help map official requests and responses to an unfolding crisis such as the Nepal earthquake.
Matched donations are a very successful policy but most donors still like to click through to see the matched donations, data visualisations on allocation efficiency and inspirational images and video clips to see the positive impact of donations.
So interim data should be an IATI focus.
NEPAL PRESS RELEASE
I read the latest news on the UK Government Department for International Development dated 20 May 2015:
The UK’s humanitarian response now stands at more than £33 million and includes:
£10 million to rebuild vital health services in the worst affected districts;
£5.3 million for UN agencies in Nepal to coordinate the international relief effort and provide clean water and shelter for affected families;
£3 million released under the Rapid Response Facility (RRF) to six charities and NGOs already working on the ground: Save the Children, Mercy Corps Scotland, Care International UK, ActionAid, Oxfam and Handicap International;
£2 million for the British Red Cross;
£5 million to match public donations to the Disasters Emergency Committee’s appeal, which will support NGOs on the ground;
a £5 million package to provide a further team of 30 trauma medics, logistical support and equipment to ease congestion at Kathmandu Airport and humanitarian experts in water, health and sanitation. DFID also deployed a team of more than 60 UK International Search and Rescue (UKISAR) responders and specialist rescue dogs;
£2.5 million for the UN Humanitarian Air Service to enable organisations already on the ground to deliver aid to isolated areas; and
more than £300,000 for Mission Aviation Fellowship (MAF) to provide two Airbus 350 helicopters to get help to more remote regions
I noted that the updated infographic by Ricci Coughlan/DFID has had 4880 views.
I looked at the UK Government DfID publisher page on the IATI website — 127 files but strangely only 1 follower for a leading national publisher:
I reviewed the 2560 rows, focused on column Q (transaction-value_value-date) and sorted the dataset into ascending date order. I filtered the dataset to rows dated 2015. The dataset includes 1 commitment in 2015 Q1, 1 commitment in 2015 Q3 and the 2015 Q1 transactions.
I then sorted the dataset on column V (receiver-org). The dataset includes 3 rows with aggregated small transactions in 2014 Q4 (deleted), 2 rows with commitments (deleted), 1 row with negative expenditure such as an overpayment (deleted), 12 rows marked “correction” with a transaction and reverse transaction (deleted) and 37 rows perhaps unexpectedly marked “supplier name withheld” in a transparency database (retained).
total transactions value = GBP 8,609,560
I downloaded the Open Nepal dataset on commitments and aid flow and filtered UK transactions:
The Isle of Man does not have a central bank and that is well received by bitcoin believers, of course!
On 10 June 2014, the Isle of Man financial services regulator explained that the policy was to support legitimate businesses within the emerging crypto sector to operate in the jurisdiction without regulation, to support best practice and that a public register would be introduced in new legislation.
On 18 July 2014, the Isle of Man financial services regulator announced guidance notes.
The Crypto Valley Summit prompted extensive discussions and — perhaps not widely enough — I recommended a voluntary public register without a fee pending the compulsory public register with a fee in the new legislation.
The new legislation (explanatory notes) is expected in H1 2015 but will not regulate crypto businesses. As at 15 December 2014 it has passed the first and second reading in the lower chamber so still requires a third reading in the lower chamber, first, second and third readings in the upper chamber and also (UK) Royal Assent in the joint chamber so it is on the right timescale.
The UK is often cited as the most important onshore jurisdiction to crypto businesses. I discussed with peer contacts and noted that even the world class UK Government Digital Service has limited public API functionality.
Most regulators and governments struggle to minimise consequential costs but increasingly real time risk management of any business on a public register is a core requirement.
I reviewed the existing Isle of Man public register of regulated banking licence holders and decided to configure a no/low cost public API with import.io as a proof of concept that even an unregulated crypto business would want to be on a voluntary public register that could be monitored with innovative automated services such as alerts (public register ping, highlight a shift to a different jurisdiction) to investors, digital wallet holders, digital currency exchanges, insurance companies, media companies, other regulators and cross-border law enforcement such as Europol and Interpol.
So, what could you do in 2 hours?
host a group coffee with some local peer contacts to shortlist crypto businesses already active in the local tech community and the inevitable 1 or 2 handfuls of stealth mode tech startups that may or may not want to be included yet (20 minutes)
draft a voluntary public register and any amendments (30 minutes)
circulate to highlight any gaps (10 minutes)
upload the summary, content and link to a holding page on the regulator website (30 minutes)
draft tweet (10 minutes)
apologise for making it look easy with import.io (20 minutes)
I’ve been lucky to have had some great discussions around public sector possibilities with open data and open banking but a meetup with Malcolm Couch, the Chief Financial Officer of the Isle of Man Government (the name on our banknotes) and Mark Shuttleworth, Isle of Man resident and ubuntu founder, centred on internal disruption, crowdfunding, Mobile World Congress, cloud hosting, Africa and an open banking mobile app undoubtedly accelerated me on a path to some recent digital currency milestones.
By default governments retain ownership of employee IPR even though most national accounts do not include any employee IPR or goodwill from residents and expats — I had wondered if that would disrupt calculations such as GDP, not unlike the recently included drugs and prostitution numbers in the latest UK statistics.
I needed a different type of engagement to reflect intellectual property rights and digital assets accumulated to date with credit card funding and the opportunity cost of not switching to the private sector — something between an employee secondment, a sabbatical, a fellowship and a social enterprise non-executive directorship to fast forward the local ecosystem but with an IPR exemption — I’ve called the net result country growth hacking!
In January 2014, I started a 1 year specialist contract on open government and open banking with the Isle of Man Government and they were already an early adopter of the shift to tax transparency via USA FATCA and UK “FATCA” and committed to FoI/RTI legislation.
I was 1 of 12 from the IATI (International Aid Transparency Initiative) technical advisory group conference in Montreal at the World Bank supported Open Contracting Partnership fringe meetup next day on the draft procurement transparency standard, with open banking inspired input. To some extent the open bank project API is a mainstream bank version of the bitcoin blockchain.
Isle of Man footprint
TGBEX launched physical bitcoins as a tangible option to collect an inevitable bit of history or to easily and safely invest in offline bitcoin.
QwikBit installed a bitcoin ATM in a very popular pub, the Thirsty Pigeon.
CoinCorner have a live exchange and recently launched a wallet and installed a payment tablet that connects to the existing POS at the Thirsty Pigeon.
CoinKite POS is installed at the Java Express coffee shop. John Middleton also hosts a bitcoin awareness night on Monday night.
A leading local hotel, the Claremont Hotel, is pending installation of inbound bitcoin systems.
CrypArt commissioned original artworks with QR coded bitcoin wallets as the centrepiece and they now have an option to include your existing keys.
A significant handful of other businesses are already exploring bitcoin transaction technology.
A trade association, the Manx Digital Currency Association, helps co-ordinate the industry such as collated responses to government policy, draft legislation and regulator consultations and to promote the jurisdiction as a responsible well regulated centre of excellence in digital currency. The committee members are all active in the industry and indeed the secretary is former head of ebusiness at the Isle of Man Government.
bitcoin milestone: declaration of beneficial ownership of a bitcoin address on a public register
As I thought more about the regulatory context of bitcoin, centred on anonymous transactions and beneficial ownership, I decided on a “mystery shopper” strategy to flush out whether or not anyone could declare beneficial ownership of a bitcoin address at the Courts of Justice and then register the document as a deed on the public register at the General Registry.
On Monday 8th September the first draft was rejected by the Courts of Justice Commissioner for Oaths as it did not meet a prescribed format and I had to amend the draft document and try again. On Wednesday 10th September I arrived at the Deeds Registry and, after some discussion at the public counter and 2 internal legal opinions — a typical deed has a grantor and a grantee and they were uncertain if the system would be able to register the deed — but 2 days later I received the deed certificate by post:
I would definitely recommend some minor but legally significant amendments to the existing procedures, but the offline option demonstrated that a beneficial ownership public register could be delivered within weeks and with existing legislation, procedures and systems.
Isle of Man Crypto Valley Summit
Max Keiser happened to mention his connection to Hollywood Stock Exchange so I knew bitcoin would prompt some serendipitous collisions. I went to the UK Parliament weekend hackathon last November hosted by Rewired State to learn new skills, so I was totally stunned when our team of strangers went on to win with political crowdfunding platform Westminster Stock Exchange inspired by Hollywood Stock Exchange. It highlighted an unexpected core issue with the parliament API and government. MPs are accountable for government performance but government data is not widely available in geocoded datasets filtered by constituency.
At the end of day #1, Brock Pierce, serial investor in bitcoin companies and recently elected director of the Bitcoin Foundation, declared the Isle of Man the bitcoin capital of the world. He also wanted a photo of the deed and the declaration of beneficial ownership of a bitcoin address.
At the end of day #2, Chris Corlett, CEO, Department of Economic Development announced that the Isle of Man Government was the first national government to request expressions of interest in supplying digital currency payment processing. The culmination of my recommendation a number of weeks earlier to Peter Greenhill, ebusiness director at the Department of Economic Development, a coffee with Owen Cutajar, a test transaction via Firmstep AchieveForms and a strategy meetup with the CFO and CTO. Not easy, but easier in the Isle of Man.
On 22nd September, 4 co-founders (Graeme Jones, John Middleton, Adrian Forbes and Richard Owusu) incorporated Garigus Limited, the first corporate entity denominated in bitcoin in the Isle of Man and perhaps the world. It is expected that the company will allow the group to progress ecosystem upgrades and other digital currency projects. Of course, a public corporate bitcoin address could be considered equivalent to a crowdfunding platform!
welcome regulation and compliance
Most regulators are still in catch up mode with digital currency technology but the Gambling Supervision Commission, Financial Supervision Commission and the Office of Fair Trading are generally accepted to be ahead of equivalent regulators, although detailed documentation and consensus agreement on the regulatory framework, minimum standards and compliance requirements is not widely expected until 2015.
A regulator may need to consider that if a brand is already strong enough to reassure players, a licensed gambling operator could soft launch a temporary technology trial in an unregulated jurisdiction anyway just to quantify demand and any issues and then relocate to support faster innovation. Should the Isle of Man be somewhere “where you can” map possibilities?
For example, BetVIP claims to be the first licensed gambling operator to only accept bitcoin, with the systems licensed in Curacao and the company based in Malta.
Well, if regulators are struggling to keep up, so are the banks!
The Isle of Man has the same issue as other British jurisdictions — UK banks are reluctant to bank or simply reject a bitcoin company. Of course, a lot of bitcoin startups are just using a personal bank account but even that option could be squeezed out with the first tax filing.
I recently progressed a new mortgage with a more reasonable Santander after both HSBC, my bank of 15 years and never a missed mortgage payment, and LLoyds Bank were very worried about 1 “high roller” £100 gambling transaction on a football match banker with a subsequent profitable cashout transaction but did not comment on a £40 bitcoin transaction, despite millions of customers gambling more every week in offline casinos with ATM cash withdrawals. You have been warned, probably best to stop anything vaguely naughty now if you want to keep your bank account!
I have a pipeline of bitcoin milestones but bills to pay so I have a seed funding round in London on Wednesday and I have also invited offers on digital assets such as altETF.com, PlayAsYouGo.com (GoCoin igaming?), ChristianBanking.com and shairholder.com to accelerate ecosystem projects with unconditional self-funding.
In a week that ended with Yodlee listed on NASDAQ, a timely reminder that I really need to finalise the next micro funding round on banknotey.com, a unique payment process to instantly extend ebusiness to the unbanked, the underbanked and even the lazy banked, before my government contract ends on 31st December 2014!